IR 05000440/1986019

Insp Repts 50-440/86-19 & 50-441/86-04 on 860707-11.No Violation or Deviation Noted.Major Areas Inspected:Action on Previously Identified Open Items,Activations of Licensee Emergency Plan & Emergency Detection & Classification

ML20204E820
Person / Time
Site:	Perry
Issue date:	07/25/1986
From:	Foster J, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204E808	List: IR 05000440/1986019 ML20204E802
References
50-440-86-19, 50-441-86-04, 50-441-86-4, NUDOCS 8608010265
Download: ML20204E820 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-440/86019(DRSS); 50-441/86004(DRSS)

Docket Nos. 50-440; 50-441 Licenses No. NPF-45; CPPR-149 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Units 1 and 2 Inspection At: Perry Site, Perry, OH Inspection Conducted: July 7- 11, 1986 Inspectors: s t 7d5~/8 Team Leader Date W.C. E8 x M. Smith //2,r/sa Date

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Approved By: nel , ief 7 ara 4 Emergency Preparedness Section Date Inspection Summary Inspection on July 7-11, 1986 (Reports No. 50-440/86019(DRSS); 50-441/86004(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of r the Perry Nuclear Power Plant emergency preparedness program: action on previously identified Open Items, activations of the licensee's emergency plan; emergency detection and classification; dose projection; protective

! action decisionmaking; notifications and communications; changes to the l

emergency program; shift staffing and augmentation; knowledge and performance ( of duties (training); licensee audits; and emergency response coordination with Canada. This inspection involved two NRC inspectors, and one consultan Results: No violations, deficiencies or deviations were identified.

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DETAILS 1. Persons Contacted M. Edelman, Vice President, Nuclear Group

• E. Riley, Manager, NQAD i

• Lyster, Manager, Perry Plant Operations Department (PP00)

• F. Stead, Manager, PPTD

• W. Coleman, Community Relations, PPSD

• P. Russ, Compliance Engineer, PPTD

• T. Heatherly, Operations Engineer, PPTD

• T. Corbett, E-Plan Training, PPTD

• J. Anderson, Onsite Emergency Planner D. Hulbert, Emergency Preparedness Coordinator R. Fobell, Nuclear Electrical Engineer R. Stratman, General Supervising Engineer, Operations Section, PP0D W. Kanda, General Supervisor, Technical Section P. Klann, Senior Project Manager T. Jameson, Nuclear Engineer, Mechanical Section S. Kensicki, Technical Superintendent K. Novak, Security Training Coordinator L. VanDerHorst, Plant Health Physics P. Moskourty, Health Physics Supervisor D. Kaopiki, Supervisory Operator W. Berg, Supervisory Operator R. Smith, Government Liasion C. Haslett, Governmental Affairs Representative J. Koski, Emergency Planning Clerk K. Cole, Director, Ohio Disaster Services Agency E. Robinson, FEMA Region V M. Brown, Lead QA Engineer J. Bahleda, Lead Auditor J. Pelcic, QA Engineer L. Pennell, Training Analyst W. King, Public Information Officer L. Shaw, Public Information Officer

• Denotes those persons attending the exit meeting held on July 11, 198 . Licensee Actions on Previously-Identified Open Items (0 pen) Open Item 440/85060-01: Technical Support Center (TSC) venti-lation system and radiation monitor readiness. The licensee has completed installation and testing of the TSC ventilation systems, and the Resident Inspector has reviewed testing records. This item will remain open pending completion of testing of the radiation

monitoring syste (0 pen) Open Item 440/85060-02: Emergency Operations Facility (EOF)

ventilation system and radiation monitor readiness. The licensee has completed installation and testing of the E0F ventilation system,

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and the Resident Inspector has reviewed testing records. This item will remain open pending completion of testing of the radiation monitoring syste (0 pen) Open Item (440/86009-01(DRSS); 50-441/86003-01(DRSS): Late notification of the U.S. Coast Guard during 1986 exercise. The licensee has incorporated this finding into training for emergency preparedness personnel, emphasizing the need to accomplish notifica-tion time goals. This item will remain open pending demonstration of notifications during the next exercis (0 pen) Open Item (440/86009-02(DRSS); 50-441/86003-02(DRSS):

Communication deficiencies between inplant teams and the control room during the 1986 exercise. The licensee has included this finding in emergency preparedness training. This item will remain open pending demonstration of control room to inplant team communication during the next exercis (0 pen) Open Item (440/86009-03(DRSS); 50-441/86003-03(DRSS):

Procedures for downgrading from an Emergency Action Level were not properly utilized in 1986 exercis Additional instructions on downgrading an EAL have been provided, and an unapproved form is currently in the review and approval proces This item will remain open pending demonstration of downgrading an EAL during an exercis . Activations of the Emergency Plan The licensee has had two activations since the last inspection, both Unusual Events (UEs), and both involving combustion of the charcoal beds associated with the Offgas Syste On June 18, 1986, a test of the temperature pull-down capability of the Off-Gas Vault refrigeration system was begun. As initial conditions for this test required an ambient temperature of 150 degrees F, electrical space heaters were utilized to raise vault temperature. As the vaults are of limited area, the heaters were in close proximity to the charcoal bed vessels. From a review of licensee documents and discussian with licensee personnel and NRC fire protection personnel, the following (limited) chronology was developed:

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Date Time Action

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i 6/18/86 1100 Initial heatup commenced 6/19/86 0600 Instrument airflow started 6/19/86 1200 Instrument airflow increased

6/19/86 1815 Temperature @ p'oint 17 = 230 degrees , "A heaters off

6/19/86 1915 Temperature @ point 17 = 206 degrees 6/19/86 2041 Temperature @ point 16 is off-scale high, all heaters off

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6/20/86 0020 Visual inspections of vault 6/20/86 0100 Refrigeration system started 6/20/86 0930 Discussion of fire possibility 6/20/86 1000 Instrument airflow stopped 6/20/86 1145 Unusual Event declared 6/20/86 1219 Nitrogen purge initiated 6/22/86 0900 All but one temperature sensor below 250 degrees F 6/23/86 1100 All temperatures below 250 degrees 6/23/86 1125 Unusual Event terminated The inspector reviewed the relevant EAL for fires, contained in EPI-A1, Attachment 2, F.I, which is as follows:

(1) Unusual Event: Fire within the protected area lasting greater than ten minutes. As indicated by: (a) Fire within the protected area lasting more than ten minutes after: (b) Initial use of fire extinguishing equipment activated by the fire suppression system. OR (c) Manual fire fighting efforts have begu This EAL is consistent with the guidance in NUREG-0654, and is appropriate to the vast majority of fires likely to be encountered at a nuclear plant. Such a typical fire would be expected to produce smoke, flames, and high temperatures in the immediate area of the fire. The EAL is, however, not conducive to classification of a fire within a contained vessel where smoke and flame are not visible, and fire fighting efforts do not include standard fire suppression equipmen As such, the licensee's action in classifying the incident as an Unusual Event at approximately 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br /> on June 20, 1986 was considered timely and acceptabl The inspector reviewed documentation for the Unusual Event, including the licensee fire report, Unusual Event Checklist, initial and followup notification forms, OSC activation checklist, OSC logbook, OSC team briefing / debriefing sheets, and initial press release, and found it to be acceptabl Documentation indicated that notifications, following classification, had been well within notification timeframe goals, and follow-up notifications had been made as require b. On July 6,1986, the licensee again attempted to perform the test of the Off-Gas refrigeration system, this time, beginning from ambient temperature (to preclude the need for space heaters). From a review of licensee documentation, and discussion with licensee personnel and NRC fire protection personnel, the following (limited) chronology was developed: ,

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J Date Time Action 7/6/86 1100 System Walkdown 7/6/86 1700 Second System Walkdown 7/6/86 1800 Instrument airflow started 7/6/86 1910 Temperatures @ 250 degrees, preparations

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to stop airflow 7/6/86 1942 Instrument airflow stopped

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7/6/86 2032 Temperatures @ 14A = 656 degrees,

@ 148 = 578 degrees

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7/6/86 2037 Unusual Event declared, nitrogen purge

! started 7/8/86 1645 Unusual Event terminated j The inspector reviewed documentation from this event, including

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Unusual Event Checklist, initial and follow-up notification forms,

! and Control Room Communication Forms, and found it to be acceptable.

j Documentation indicated that all notifications were well within

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notification timeframes.

]. No violations of regulatory requirements or deviations from commitments l were identified.

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j Emergency Detection and Classification (82201)

. The Perry Nuclear Power Plant Emergency Plan (PNPPEP), Section 4.0,

" Emergency Conditions," was reviewed. Four levels of emergency conditions are defined in this section: Unusual Event (UE), Alert (AL), Site Area Emergency (SAE), and General Emergency (GE). The GE j condition includes instructions that the Emergency Coordinator will

issue Protective Action Recommendations (PARS) to shelter the general public within a two mile radius of the plant and out to five miles

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in the three downwind sectors.

j Section 4.0, Table 4.1 of the PNPPEP details the Emergency Action Levels

! (EALs). Differences in the format and content were noted between the EALs in the PNPPEP and the implementing instruction (EPI-la). The l content of the EAL in the implementing instruction includes specific j indication by point number identification. The EAL in the PNPPEP does j not include such point number identification. The layout and format of the EALs in the implementing instructions is considerably different than those in the PNPPE A spot check between the EP and the implementing

. instruction indicated good correspondence for each EAL.

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The conditions listed in the PNPPEP corresponds to the guidance contained

! in NUREG-0654, Appendix 1. However, some of the distinctly observable 1 events that guide the user to the emergency condition level are suspect or ambiguous. Several examples are listed in the appendix to the report.

The licensee has committed to perform a detailed review of the EALs.

, This will be tracked as Open Item No. (440/86019-01; 441/86004-01).

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Walkthroughs were conducted with ten personnel assigned to the Perry

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emergency program. Nine individuals were assigned to the Technical Support Center (TSC), and one was assigned to the Emergency Operations Facility (EOF). Walkthroughs consisted of ouestions relating to each individuals responsibilities, and where appropriate, a demonstration of the use of procedures and equipment. Two Radiation Protection

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Coordinators adequately demonstrated the use of the backup dose

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projection computer system. The primary dose calculation system was down fnr routine maintenance during the demonstrations. All personnel

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were kncwledgeable of their responsibilities and adequately demonstrated

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(as appropriate) the use of Perry Emergency Procedure :

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Preparationprocedures emergency for the walkthroughs including theincluded following:a review UnusualofEvent selected Perry),

(EPI-2a I Alert (EPI-3a), Site Area Emergency (EPI-4a} and General Emergency i

(EPI-Sa). It was noted that in these procedures the responsibility for classifying an action level was not listed as a non-delegable responsibil-ity for the Emergency Coordinato It is recommended that the procedure

specify that classification of events is a non-delegable responsibility

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assigned to the Emergency Coordinato In practice, each Emergency Coordinator fully understood that if was the Emergency Coordinator's sole responsibility to approve the classification level prior to release to

offsite authorities.

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! Protective Action Decisionmaking (82202)

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Protective Actions and Guides EPI-88, (Revision 3) was reviewed. This instruction provides that the Emergency Coordinator is responsible for

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approval of all protective action recommendations. Protective Action

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Recomendations are developed by the Offsite Radiation Advisor and the

Radiation Protection Assistant, based on Offsite Dose Calculations

!' Procedure EPI-B7 and Radiation Monitoring Team reports. The procedure includes a benefit analysis of sheltering vs. evacuation, i Interviews /walkthroughs with two Emergency Coordinators indicated that i they were fully aware of their responsibility to make protective action l recommendations to offsite agencies. Each Emergency Coordinator demonstrated the capability to use the Perry emergency procedures.

. It is recomended that in the definition Section (Section 3.1),

I " protective actions," be changed to include those emergency measures taken before or after an uncontrolled release of radioactive material has occurred. Currently, the definition does not include measures taken

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before such a releas I l No violations of regulatory requirements or deviations from commitments i were identified.

! Comunications (82203)

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Procedure EPI-B1, " Emergency Notification System" (Revision 4), which

details guidance and responsibilities for notifications of County, State, i federal agencies and licensee Emergency Response Organization Personnel

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and offsite emergency facilities was reviewed. The procedure describes in adequate detail the methods and equipment to use for notifications of the above organizations and personnel. A dedicated phone (blue) is used to contact the local counties and the State of Ohio. Back up phone systems are available in the event the dedicated phone system fail It was recommended that a note be incorporated into the procedure to remind communicators not to provide the Perry Plant Control Room telephone nunber to the local and State agencies when using the backup phone system, to prevent compromise of the authentication schem Licensee personnel indicated that the need for such guidance had been identified, and changes to add the note were in proces . Changes to the Program (82204)

Through discussions with licensee Emergency Planners and random reviews -

of selected procedures, facilities and equipment, the inspector verified that no major changes have been made to the licensee's program since the last inspectio The General Supervisor, Community Relations Section, maintains overall authority and responsibility for the Emergency Preparedness Program. The Emergency Preparedness Coordinator is directly responsible for supervising four Emergency Planners in the maintenance and coordination of the progra The inspector reviewed the Operations Manual Procedure PAP-0507 and determined that changes to the Emergency Preparedness Program are reviewed and approved by appropriate management. The inspectors interview with licensee representatives verified that there had been no significant changes in the organization or assignment of responsibilities for the Emergency Plan Organization since the last inspectio The interviews also revealed no significant changes in the organization of offsite agencies since the last inspectio The inspector reviewed the licensee's program for distribution of changes to the Emergency Plan and Implementing Procedures. Licensee representatives indicated that the Licensing Department had distributed controlled copies of the Plan and Implementing Procedures and the Administrative Department had also distributed controlled copies as part of the Operation Manual system. The Licensing Department is presently recalling all their

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distributed controlled copies and the Administration Department will assume control of distribution of changes to the Emergency Plan and Implementing Procedures through the Operation Manual distribution syste At the time of this inspection the Emergency Preparedness Program was in the process of annual review. All Letters-of-Agreement were being reviewed by offsite authorities and will be returned to the licensee with signature The inspector also reviewed the drill records of 1985 and 1986 and verified that all required drills were conducted at the frequency specified in the licensee's plan. The inspector reviewed inventory i

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procedures for Emergency Kits and ERF supplies, An independent inventory of E0F facilities, emergency kits and decontamination facilities, was also conducted. All inventories have been completed at the frequency specified in the Emergency Plan and Implementing Procedure The Prompt Notification System is tested biweekly with siren activation by the county authorities on the second Wednesday of the month at 11:00 A Licensee personnel check each siren to ensure proper activation. Any problems are immediately reported to the local Service Center for repair or replacement. The inspector reviewed licensee records and interviewed FEMA personnel and verified the Prompt Notification System was maintained and tested as required by NUREG-0654, Appendix 3, and FEMA REP-1 . Shift Staffing and Augmentation (82205)

The inspector reviewed minimum shift staffing and capabilities for all shifts and concluded the emergency response organization met the guidelines of Table B-1 of NUREG-0654, Revision 1. Table 5-1 of the

. Emergency Plan lists the position, reporting function, location and responsibilities for each position. An administrative system is in place to assure that offsite emergency response personnel are available as needed to meet the 30 and 60 minute response times. Licensee personnel meet functional requirements for staffing by having assigned emergency tasks related to their normal dutie The call-out list of emergency personnel is updated and distributed quarterly. The notification system and call-out procedures are found in EPI-B1 and EPI-8 The licensee successfully activated the call-out procedures as part of their April 1986 exercise; however, shift staffing and augmentation drills are not part of the Emergency Preparedness Plan drill requirement Semiannual activation of the call-out procedure is encouraged to maintain and demonstrate licensee response capabilities in this area. One of these i semiannual activations of the call-out procedure should be conducted during off-hours to ensure adequate 24-hour staffing capabilities.

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The licensee was encouraged to incorporate semiannual activation of emergency call-out procedures into their emergency preparedness plan and drill program. A commitment to this effect was received at the exit interview. This will be tracked as Open Item No. (440/86019-02; 441/86004-02). Knowledge and Performance of Duties (Training) (82206)

The inspector reviewed the licensee's program for training personnel involved in the emergency program, and tracking the completion of training modules to ensure individuals assigned emergency responsibil-ities were qualified for their positions.

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Discussion with licensee personnel indicated that initial emergency training was performed by contractors, who either wrote the training modules or assisted the licensee staff in their development. Presently, an overall revision of the training modules is in progress to make them position-specific. The goal for completion of the new position-specific modules is August, 198 The inspector reviewed the course objectives, course description, references, lesson plan, handouts, transparencies, exam and answer code for the training module " Emergency Response" (EP-0901-001-01), and found them to be acceptabl Discussion with cognizant personnel indicated that the instructor provides an " instructor report" which contains the names and grades of attendees, which is sent to the attendees supervisor and to Support Services, where the information is placed on a computerized tracking syste The computer system provides a printout containing name, position, required training modules for the position, a waive /requalifi-cation date, and a control number. When an individual has passed the required requalification date, the tracking system no longer prints the requalification date, and an easily identifiable space is left in the printout. The system does not lose the retraining date, but does not print it out under the current program. This can be a problem in that the retraining date is not immediately availabl A " Routine Tasks" system alerts emergency preparedness personnel to request a training system printout on a routine basis. A problem was noted in that the Emergency Plan requires retraining in required modules on an annual basis, and the computer system uses a twelve month retraining schedul As noted above, training modules ne under revision, which will require changes to the tracking system to match the new training progra Based on the above findings, the licensee's program in this area is adequate, however, the following item is recommended for improvement:

• Modify the Emergency Plan to specify a twelve month (plus or minus twenty-five percent) retraining schedule, and revise the computerized tracking system so that the retraining date continues to be printed when the date has passe Consider programming to have the tracking system issue a three-month warning when a retraining period is nearing the en . Public Information Program (82209)

The licensee's emergency public information program meets the requirements of 10 CFR 50, Appendix E. The 1986 edition of the Emergency Information Handbook was in the annual review process and should be distributed to all residents in the ten mile EPZ by September, 1986. The inspector's

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review of the handbook indicated that its contents met the guidance of NUREG-0654, Revision The licensee also places brochures at offsite

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agencies and posters are distributed to the State for placement in game or park areas.

j Emergency information has been printed in the three local telephone directories covering the ten mile EPZ. In addition to the distribution i of the Emergency Information Handbook, the Community Relations Department

!. participates in an annual media training day, public speaking for local

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groups (upon request), and tours of the plant facilitie The inspector reviewed training records, schedules and lesson plans

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involved in offsite training sessions. An extensive training program has been developed by licensee, state and county personnel. All levels

of offsite personnel receive specialized training coordinated to their

particular function. Training records revealed approximately 4,000 state

and local personnel have been qualified through this coordinated effort.

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! The inspector determined that public information and offsite coordination

[ areas of the emergency preparedness program continue to maintain an

excellent level of performanc I 1 Licensee Audits (82210)

The inspector verified that the licensee had in place provisions for i conducting an independent annual audit of the Emergency Program. -In j addition, the surveillance program, as applied to the Emergency Plan

activities, was reviewed.

! Perry Operations Procedures (0208, Revision 1, dated 10/18/85), indicates '

that the Manager, Perry Project Services Department, is responsible for j obtaining an independent group to perform a detailed technical review of j the Emergency Plan.

i t The Perry QA Plan, Appendix A (Revision 3, dated 6/5/86) provides for

review of audits of the PNPP Emergency Plan and implementing procedures l by the Nuclear Safety Review Committee, Audit Subcommittee.

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! Appendix E of the QA Plan (Revision 1, dated 10/30/85), provides a matrix indicating which sections of QA Plan requirements are applied to emerger, icy .

3 planning activities. An annual audit of emergency planning activities is

, scheduled.

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j Audits at the Perry site follow the standard audit pattern for production .

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of an Audit Plan, review and approval of the plan, development of an Audit

Checklist, and notification of the pending audit. Audit findings are classified as Audit Findings Requests (ARs), or Corrective Action Request Audits may also contain Open Items and Recommendation *

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l The inspector reviewed the two audits which have been performed relative to Emergency Planning to date.

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Audit PIO 85-02 was conducted by the QA Department during January 9-29, 198 AstheEmergencyProgram, facilities, equipment,andpersonnel were not in their final configuration," no audit findings were issue Rather, a list of sixteen open items (with some sub-items) was generated and presented to the Emergency Preparedness Coordinato Audit PIO 86-19 was conducted by personnel from the Operations QA Department and a consultant during April 14-16, and May 5-16, 1986. This audit included observation of the May 15, 1986 Emergency Exercise, and resulted in three Action Requests, seven open items, fifteen recommenda-tions, and five strengths (areas where the program showed exceptional merit). The audit was comprehensive and detailed. As requested by the licensee, a separate section (Section 7.0) dealt with the adequacy of the interface with offsite authorities and provided a list of audit sections related to the offsite interface. Licensee personnel indicated that when the audit report is approved, it will be distributed to offsite authoritie This distribution will meet and exceed the requirements of 10 CFR 50.54(t).

The inspector reviewed the Action Requests generated by the audit and verified that corrective action was in progress or had been completed for the item Surveillances are performed by a surveillance group, according to a yearly surveillance schedule based on the QA Plan, Table 18-1. Surveillances had been scheduled for calendar year 198 . Interface with Canada

i The inspectors review of the Perry Emergency Plan indicated the licensee's awareness of the necessity to notify a small land area of Canada located within the 50 mile EPZ of the Perry Power Plant. According to licensee interviews, all notifications and updates are provided to the provincial government by State of Ohio authorities beginning at the Alert level. A review of the Ohio plan for Response to Radiological Emergencies at Licensed Nuclear Facilities verified this procedur An interview with the Director, Ohio Disaster Services Agency (ODSA), indicated that the State of Ohio will provide desk space in the State E0C for two representatives who will maintain communications with provincial authorities. Coordination of information and response will occur between the State of Ohio and the Ontario Provincial Governmen Prior to the April, 1986 exercise, provincial authorities indicated their interest in exercise participation to both the licensee and state governmen The licensee responded by arranging a one-on-one training session for the representative, plus arranging for observations in the

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E0F and local E0C. The State arranged for two representatives to observe State participation in the State E0C. Provincial authorities have indicated that they will participate in future exercises or activations at the State E0C.

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13. Open Inspection Items Open inspection items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. Open inspection items disclosed during the inspection are discussed in Sections 4 and . Exit Interviews

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The inspectors met with the applicant representatives denoted in Paragraph 1 on July 11, 1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report. The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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APPENDIX EAL Review Comments The following comments were developed during a brief review of the Perry Plant EALs. This was not considered as a detailed review, and was performed by personnel lacking plant-specific knowledge. For each EAL, the Emergency Classification, PNPPEP number and condition, relevant NUREG-0654 guidance (if applicable), and reviewer's comment will be listed, Unusual Event PNPPEP No. 8: Loss of containment integrity requiring shutdown by Technical Specifications (TS), and shutdown not achieved within the required time perio NUREG-0654: Loss of containment integrity requiring shutdown by T Comment: The Perry EAL is more limiting than that contained in NUREG-0654, in that the NUREG provides for an Unusual Event in each instance where shutdown is required by containment integrity Technical Specification Unusual Event PNPPEP No. 9: Loss of Engineered Safety Features (ESF) requiring shutdown by TS, and shutdown is not achieved within the required perio NUREG-0654: Loss of ESF or fire protection system function requiring shutdown by Technical Specificatio Comment: The Perry EAL is more limiting than that contained in NUREG-0654, and the loss of fire protection system function is not addresse Unusual Event PNPPEP No. 10: Fire in the protected area lasting more than ten minutes

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after; initial use of fire extinguishing equipment activated by the fire suppression system OR manual fire fighting equipment efforts have begu NUREG-0654: Fire within the plant lasting more than ten minute Comment: The Perry EAL is more limiting than the NUREG guidanc Unusual Event PNPPEP No. 20: Any instance that, in the judgement of the Shift Supervisor,

. warrants declaration of an Unusual Event where increased awareness is required by plants staff and/or offsite authorities.

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Appendix 2 NUREG-0654: Other plant conditions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g.,

cooldown rate exceeding technical specification limits, pipe cracking found during operation).

Comment: That portion of the NUREG that requires shutdown by Technical Specification requirements or other than normal controlled shutdown is not addressed in the PNPPE Alert PNPPEP No. 3: Reactor coolant leak rate greater than 50 gpm with reactor at operating temperature and pressure: confirmed by one of the following; Drywell (DW) floor drain sump fill rate above 50 gpm AND DW floor drain pumps continuously running AND increase in floor drain tank level.

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NUREG-0654: Selected parameters should be directly observable.

J Comment: The DW unidentified sump fill rate meter pegs high at 30 gp To determine greater than 30 gpm rate, a calculation based on sump pump run time must be completed. Therefore, the indication is not directly observabl Alert PNPPEP No. 11: All alarm (annunciators) lost for more than 15 minute NUREG-0654: Most or all alarms (annunciators) los Comment: The Perry EAL is more limiting than the NUREG guidance, and does not address partial loss of alarm Site Area Emergency PNPPEP No. 1: Known loss of coolant accident greater than makeup capacity, as indicated by water level below 18.25 inches AND drywell pressure greater than 1.68 psi NUREG-0654: Not applicabl Comment: The indications selected are extreme. At the points selected, the reactor vessel level is 180.5 inches below the low level alarm (199 inches), and the following events would have occurred: Reactor Vessel Low Level alarm, Reactor Trip, RCIC initiation, HPCS initiation, containment isolation . . .et ___ . _ _ - . _ _ _ _ _ . _ - - . _ _ _ _ _ - - . _ . - _ - __ _ _ . - - --

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Appendix 3 Site Area Emergency PNPPEP No. 2: Degraded core with possible loss of core geometry. Main steam monitors is listed as 3.6X full power background level. Under the General Emergency condition No.1, " Loss of Fission Product Barriers,"

the MSL radiation hi alarm trip is listed as 3X ncrma '

NUREG-0654: Not applicabl Comment: The 3.6 and 3.0 times normal listed parameters are inconsisten It is unlikely that anything above 3.0 times normal would be a valid indication of actual flow as the main steam line isolation valves shut at three times normal radiation level Site Area Emergency PNPPEP No. 7: Complete loss of any function needed'for plant hot shutdown, as indicated by: inability to scram AND inoperative standby liquid Control System OR all Safety Relief Valves (SRV) inoperative AND Suppression Pool inoperative AND Suppression Pool Cooling mode of RHR inoperative AND HPCS OR RCIC inoperativ NUREG 0654: Not applicabl Comment: The AND and OR logic statements need to be checked for correct-nes Examples; discussions with plant personnel indicated that if either HPCS or RCIC is available, then het shutdown capability is assure Therefore, the OR statement should be an AND statement, Suppression Pool inoperative AND Suppression Pool Cooling mode of RHR inoperative. Loss of either system would be a loss of plant function for hot shutdow Therefore, it appears that this should be an OR statemen , Site Area Emergency PNPPEP No. 10: All alarms (annunciators) lost more than 15 minutes and reactor is not in cold shutdown or plant transient initiated while all alarms are lost; as indicated by loss of all alarms for more than 15 minutesANDReactorTemperaturegreaterthan200degreesFANDReactor Mode Switch is not in " Shutdown,' OR Plant transient initiated as demonstrated by: Reactor water level less than 18.25 inches followed by ECCS initiation OR Reactor Temperature change greater than 100 degrees F per hour OR abnormal reactor pressure in excess of atmospheric pressur NUREG-0654: Most or all alarms (annunciators) lost and a plant transient initiated or in progress.

, Comment: Loss of all alarms for greater than 15 minutes and greater than 200 degrees F and mode switch not in shutdown is the same (normal operations)

as the Alert Classificatio The transient selected are extreme, or, as in the case of temperature change, not directly observable.

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